11 
1 our concerns, but we intend to submit extensive written 
2 comments on the proposed guidelines. 
3 I would briefly like to discuss the following 
4 five aspects today: One, the need to rewrite sections of 
5 the guidelines to eliminate ambiguity; two, mechanisms for 
6 assuring adequate public participation in NIH activities 
7 mandated by the guidelines; three, membership in the 
8 Recombinant DMA Advisory Committee; four, membership and 
g responsibilities of the institutional biohazard committees; 
10 and five, confidentiality. 
11 EDF is concerned that the poor quality of the 
12 drafting of the guidelines will result in confusion and 
13 compliance failures. There are many sections of the 
9 
14 guidelines that you can pore over for hours and still not 
15 fully understand what is required. 
16 As presently written, instructions for persons 
17 conducting DNA activities are spread throughout the 
18 guidelines themselves, the Director's decision document, 
19 the Environmental Impact Assessment, and appendices to 
20 these documents. And often these documents contradict 
21 each other. But only the guidelines have the indisputable 
22 force of law. 
23 Moreover, the guidelines are sometimes so vague 
24 that their intent is unclear, and problems are sure to 
25 arise. 
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